3 Henkel Position on RoHSElectrical and electronic equipment (not all end users)AppliancesComputersTelevisions, video recordersHexavalent Chromium (CrVI) is critical element for metal passivation treatments listed in RoHS regulationMust contain less than (0.1%) 1000 ppm. Hexavalent chromium or contain no intentionally added hexavalent chromium in any homogeneous layerHenkel position is that passivate coatings do not become a homogeneous layer with substrate, but, the discontinuous layer of the passivate. (IBM agrees with this position).Chromium free products are compliant simply because there is no chrome presentChromium III (trivalent) products are compliant in both the product and as-dried surface since Cr(VI) is below 1000 ppm and no Cr(VI) is intentionally added.Conversion of Cr(III) → Cr(VI) will not happen under “normal” circumstancesPH≥14 or extreme oxidation are requiredPractical basis, Cr(VI) not present during life-cycle of the coated materials.